As NASL has reported, the Bipartisan Budget Act of 2018, which was enacted February 9, 2018, contained a number of provisions that may have impacted SNF Part B therapy claims, including the Work Geographic Practice Cost Index (GPCI) Floor and the permanent repeal of the outpatient therapy caps as of January 1, 2018.

Due to the retroactive effective dates of these provisions, Medicare Administrative Contractors (MACs) were provided additional instructions to automatically reprocess claims impacted by this legislation from April 1 to no later than six months after this date. For the limited number of SNF providers impacted, providers will not need to request any reprocessing unless they believe that the MAC systems did not automatically reprocess the impacted claims.    

In addition, the Centers for Medicare & Medicaid Services (CMS) posted an MLN Matters article that provides additional details about these changes impacting SNFs. The instructions to the MACs to reprocess claims contain the following specifics:

• The MACs will reprocess therapy claims with the KX modifier containing Dates of Service in Calendar Year 2018, which were denied prior to the implementation of the updated legislative effective dates issued on January 25, 2018. NOTE: For institutional claims, these claims will include revenue codes 042x, 043x, or 044x and modifiers GN, GO or GP.
• The MACs will reprocess therapy claims with the KX modifier that were denied due to an invalid date provided by CMS on February 12, 2018.
• The MACs will reprocess Medicare Physician Fee Schedule claims for localities and States impacted by the Work GPCI Floor fee increase for Dates of Service in CY 2018.
• MACs shall ensure all reprocessing actions have been initiated within 6 months of the issuance of Change Request (CR) 10531.
• MACs will reprocess claims that cannot be automatically reprocessed only if such claims are brought to the MAC’s attention.

The official instruction, CR 20531, issued to the MACs regarding this change is available online. Any questions with this change should be directed to the MACs (see CMS’ Interactive Directory for MAC contact information).